As we have discussed, the latest revisions of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) has a new criterion for categorization of flammable gases.  The GHS now has sub-categories of CAT 1 Flammable Gases:  1A and 1B.  CAT 1B flammable gases have a fundamental burning velocity of less than 10 cm/s.  Never have I dealt with burning velocities...

Your inquiry relates to the enforcement of OSHA’s Process Safety Management (PSM) standard, 29 CFR 1910.119, to two hypothetical scenarios you provided that are related to upstream oil and gas production facilities. Background/Scenarios: In your letter, you describe the following scenarios involving natural gas processes that are in the production phase of upstream oil and gas operations. Both...

One of the topics we have debated about 1910.146 is whether (c)(5) and (c)(7) entry methods could be used simultaneously on the same space.  I was a resounding “No” but since we could never get an official answer from OSHA, there were many in our profession who felt it was acceptable to use (c)(5) and (c)(7) entry methods simultaneously on the same space.  Then in 2015, OSHA published...

This article should have been written 20 years ago as this topic has been misunderstood since OSHA published 1910.146 way back in the early 1990’s.  We still see many facilities misunderstanding what a NON-Permit Required Confined Space and more importantly how one is created.  First, OSHA defines a NON-Permit Required Confined Space in both the General Industry and Construction standards:...

Have you ever seen a Permit-Required Confined Space (PRCS) labeled using the term “Confined Space” instead of “Permit-Required Confined Space”?  Does it matter what we call them?  … HomeRead More »

A gas distributor and its parent company have agreed to pay $257,000 to settle RMP violations discovered during inspections following a fatal 2013 explosion at a Texas facility.  On the morning of February 9, 2013, at the La Porte #1 facility, there were explosions and a fire. The Incident occurred in the Gravimetric Unit (“Unit”) at the facility, where the blending or filling of cylinders with...

Sitting here relaxing this Sunday afternoon, I am comforted in now knowing 100% why engineering controls rule over Admin Controls and PPE. As soon as President Trump and his team mentioned some alternative treatments this week for ridding the body of the virus, a lot of folks latched onto the ideas. Our society, which is indicative of our workplaces, wants some easy way of achieving their desired goals....

At 2:00 p.m. on September 20, 2019, an employee was inside of a 10,000-gallon fiberglass gasoline storage tank and was draining some brine water while cleaning the tank. The employee used a drill while inside the tank and ignited the gasoline vapors, exploding it and setting it on fire. The employee was caught in the explosion and was killed.  The environmental company has received seven (7) serious...

OSHA has cited a carpet restoration, plumbing, and resurfacing contractor for exposing employees to safety and health hazards after a fatal incident at a worksite. The company faces $183,127 in penalties.  OSHA initiated an investigation after an employee suffered fatal injuries after inhaling lacquer thinner, which was used to resurface a bathtub. OSHA cited the company for failing to evaluate...

The United Nations issued its 8th Revision to the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) late last year and in this 8th revision we have some very good guidance on Combustible Dust (COM DUST).  For the record, OSHA is considering adopting the 7th Revision; we currently are using the 3rd revision in our 1910.1200 compliance.  So this is not so much about...

When we have a hazardous material that poses either a physical hazard such as a flash fire/explosion or a health hazard we need to manage this hazard using our hierarchy of controls.  The first control is to see if we can use a “safer alternative” which we call “Elimination/Substitution”.  But if this is not possible we go to our next layer – Engineering Control(s)...

In the past several weeks I have tried to explain the fundamental safety practices of storing the alcohols many businesses are using to make hand sanitizer.  This post I wanted to share two videos that show the flammability of these hand sanitizers and an excellent video from NFPA about how the changes at businesses such as distilleries may, in fact, place them at a higher risk as the concentration...